ML19352A001
| ML19352A001 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/03/1980 |
| From: | Hovey G METROPOLITAN EDISON CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19351G574 | List: |
| References | |
| TLL-308, NUDOCS 8102250333 | |
| Download: ML19352A001 (5) | |
Text
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Post Off.ce Box 480 w
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717 9444041
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we,ter's 0. rect 0.ai.wmcer July 3, 1980 TLL 308 Office of Icapection and Enforcement Atto:
Mr. Boyca H. Crier, Director Region I U. S. Nuclear Regulatory Cot:nission 631 Park Avenua King of Prussia, Pennsylvania 19406
Dear Sir:
Three Mile Island Nuclear Otation, Unit II (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Cachined Inspection Report 50-289/80-02 ; 50-320/30-02 This latter is our respcase to the items in the Combined Inspection Report, refer-cecad abov2.
Attach:d please find our responses to'the apparent items of nonexpliance
- e concur with the findin;',s in Items A, 3
(inf ractions), Ite=s A through I.
and D, and our correctiva actions are specified in Attachment No.
1.
Items C and I, hcwaver, we take exception to the findings as inf ractions.
Our reasons
%*e are and justifications for ta'.cing exceptions are outlined in the attachment.
pr2 pared to =eet with you at your convenience to resolve these items.
Sincerely,
$ V// A%i f lC.K.Hovey f/b r. ~
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Director, TMI-II C'G: SIC: dad cc:
_3. J. Cnydar I
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l ITEM _A Area of Apparsnt Infraction - Leck of training of vendor personnel in the Administrative Controls for procedural i=ple=entet$ on.
Rasponse - A memorandu= was issued February 15, 1980, which r2 quired all personnel utilizing station procedures in conducting their business to read and understand, (with respect to use of procedures), AP 1001 "TMI Document Control".
Responses to the me=o by the tasked uanagers and supervisors indicate that this action is co=plete.
In addition, the vendor individual involved in the infraction was instructed in uce of procedures and the need to f ollow the= as written, or obtain a written approval to change the procedure es appropriate.
Tha Training Depart =ent has instituted instruction on use of procedures as part of the General E=ployee Training Progra=,
contracter personnel will start receiving this training in Jul,y, 1930.
All personnel who utilize Station Procedures in conducting their business, will have been given this training by December, 1930.
ITEM 3 Ar2a of Apparent Infraction - Control Rocs Operator's failure to properly L=ple= ant varicus aspects of Station 'dealth Physics Procedure 1631.2.
Response - In order to ineure ce=pliance with various approved prece-dures, the Unit-II Shift Fore =en have been directed to insure that the Control Roo= t racks all procedures involving operating syste=s er evolutions that may result in a gaseous er liquid radioactive release.
4 r eprby.-st ep. basis' The Control ?.co= will track the procedure on a
whanever possible, depending en cocaunication availability and the ti=a constraints between steps.
Where restricted an a step-by-step basis, a briefing will be held by the Shif t Foreman, the control ace =
Cperator, and the persen doing the evolution to ensure understanding and ce=pliance with the procedure.
f In addition, tha Plant Operations Depart =ent has been instructed in A?.1C01, "T:C Docu=ent Centrol" as per response to Infraction
'A' indicated.
ITEM C Area of Apparent Infraction - Nonperfat=a.ce of suitsble mesouvevents of radioactive materials in the air instde Make-up Pump Roc = 13 :=
February 11, 1930.
Response - The licensee does not agree that its e=crgency rerp:nse actions on February _ 11, 1950, were in noncc=pliance with the Code of Federal Regulatienc. -As can.be seen, the code of Federal Regulatices, Titic 10, Part 20, does not address the erergency ~rzuponse stend:rds - --
as such.
Althou3h the licensee acknowledges that the precise ne2 surer 7r:
cf the cencontration of radiological. = ate. rial in the cir was not made end =cy have been desirable, it was not a vital ele =ent in raintaining radiologic =1 control.
In this specific emergency, an uncontrolled release of primary cociant was taking place which was rerulries in : ---
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ralcase of radioactive materials.
Some of the radioactive caterial and subsequently was released via the f acility was in a gaseous form l.
ventilation systet.
The licensee concluded that the uncontrolled release =ust be secured as pro =ptly as possible.
To that objective.
Station Health Physics Procedure '670.15 "Pos t-Accident Re-Entry and Recovery Plan", dated January 16, 1978, states in Paragraph 1.1 -
"In any radiological emergency, the i= mediate phases of responsive action include incitial actions directed toward protection of the public and i==ediate planned action directed toward ter=ination of the incident, containment of effluent, establish =cnt of incident boundaries, establish-ment of control and channeling of infor=ation and protection of the facility and equip =ent".
The licensee considers its' actions were in accordance wi th this prog.edure.
Station Health Physics Procedure 1670.3 " Emergency Ee-Entry for Repate or Rescue", dated January 16, 1978, states in Paragraph 4.3, "During any emergency, personnel radiation exposure must -te.evaLaated _on a risk-Every ef f ort should be made to =inimize exposu're".
benefit basis.
Aasin. the licensee considers its sctions were in confor=ance with this require =ent.
the licensae hid previously known of At the time of the emergency, airborne activity levels in this area resulting from a primary coolant icak in August, 1979.. Personnel entering the area were briefed crior to catering and were given stay-times and were equipped with self-centained braathing air units.
No entries were =ade into the area without self-contained units. As stated in the Nuclear Regulatory Cenmissien report.
Since this is an area of Unit II air sa=ples were taken outside the roc =.it was known in advance of this problem which has not been decontaminated.
This was confirmad thIt high levels of racioactivity were paesent.
Whole body
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during the emergency by appropriate dose rate =easura=ents.
counts were below the screening level.
Again, the licensee acknowledges of concentra-the specific wording of 10 07R 20 relating to =easure=ent tions of airborne radioactivity, but feels that the 10 CyR 20 does notThe adequately address emergency situations and e=ergency requirements.
licansee is of the opinion that =easurements of airbcrne rcdioactinf ry should be =casured in routine conduct of' business and, those recuired in e=sracncy situations =ay not be the same. Under the e=ergency circu= stances, An air sa=ple it was necessary that entry be made to secure the leak.
would have required the expenditure of additional =an-res and in the the entry would still have to be made. Considtring all of final. analysis, the various requirements, the licensee concludes that its actions were proper and that no violatien of 10 CFR 20 exists.
To clarify the license 2's actions in e=ergency situations, the emergency procedures are scheduled this ti=e.
These for review and some are in various stages of revision.at revisions will address more precise emersency aerion responses and attempt of to dir.tinguish between routine plant operctions and emergency respvnse operations involving e=arsency situations.
These will be co=pleted by 2=erser.cy Planning.
3y utilizin; good as low as reasonably achievable precepts the. highest less than 100 uhola body exposure for this e=crgency was maintained at mee=,~sithough the exposuro 1cvels'in the roc = were very high.
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A
,netorn=3 - Tho specific problem of an unposted radiation area has been cor:decad by ths licensen.
In addition, subsequent surveys conducted in May of 1980 has cenfirmed co=pliance with radiation area postina it requirements.
In reviewing this item to ensure future compliance, was noted that exis:ing procedures defining radiation survey requirenents are not adequate to ensure ocnitoring personnel consistently operate to a satisfa: tory s:andard.
This precedure vill be revised to detail radiation survey requirements.
This vill be co=pleted by July 31, 1980.
Although the licens2e considers that full cocaliance has been achieved.
to ensure that compliance is =aintained while the survey procedure is vi ch bein3 revised the Radiological Monitoring Manager vill review,be used to responsible parsonnel, this problem and techniques which must ensure the error'1.3 not repeated.
ITEM E Area of Apparent Infraction - Inadequate surveys of airborne c'adio-activity at the spent fuel pool in the Fuel Handling Suilding during
=cv:nsnt of process vatar.
P.nsoonse - The licencee believes that the surveys perforned at the SF?
at :he ti=es specified in Inspection Report 30-02 were adequate and satisfiad the requirements of 10 C7R 20.103.a. (3).
prior to :ne ransfer of vnter to the spent fuel pool, the possibility of airborne tritiur uns censiderad.
Calculations indicated t hat thz tri:ium concentration
.in the process vater to be ';:.m sf er---d to the S7?
'3' vsc not high enough :o crea:2 an airborne tri:iu= probles.
The accrocal to use the
'ased en :5e calcula-ocol vos siven by R2diological Cnnerals Management r
tiens.
3etvaan February 16, 1930, and February 27, '.950, when processed vater was being transferred :o the SF?
'3' (on a discontinuous basis),
seven (7) tritium air sa==las were taken to verify tha: airborne tritiu:
concancrations were belov the maxi =u= anticioated le/els.
On the dates when no sa= oles are filed (February 13, 19, 20, 22, 23, 24, and 25) ne transfers of :ritiatad water vera mace.
Tha ti=es of these sacoles, when c:==xed-es.the -e.d.d.: 'lC. :.ic2s cha:
praesss vatar was pumped to the SFP
'3', reveals that sa=ples were taken during various conditions includ'.ng:
befora pu= pin?,, during puccine, af:er pu=:ing, and betvean pu= pings.
A schadula of samoles taken /ersus pu= ping times is as fol2cus:
OAU WATER IRANS?ER SA'PLE REC t'*.~ 5 Tnt?.s 0.:C i /.- M 10,*
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02/15 0217-1350 1730 4.74 x 1845-2005 l
i 22/17 0010-0400 0550-2005 21c0 2.c3 x 10 i
1620-2037 02/21 0045-0520 0100
- 3. c2 x 16_'1 1000-1200 0545 3.23 = 10 '
02/21 2130 to 0110 02/27
.02/25 2103
<1.S x 10,'
02/26 2235 2.6 x 10-02/27 0140 3.1 x 10~
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a Respenna to ITEM E (cent'd.)
Six (6) of these seven (7) samples indicated detectable levels of airborne tritium activity.
However, the highest dece.cted level was e
4.74 x 10 uCi/ml detected an the first day of ou=oing to the cool.
7
-6 This level represents less than 10T. of M?Ca for tritics (5 x 10 uCi/si).
For the retaining sa= oles detectable levels of tritium ranged f rom 7
7 2.03 x 107 uCi/ml to 3.92 x 10 with an average of s 3.0 x 10 uC1/ml.
Based on the calculations of the samples, it was and is the Licensee's opinion that the requirements of 10 CFR 20.103.a. (3) were beint satisfied and that =casurements of radioactivity excreted from the body were not appropriate or necessary.
Apparently, the inspector (s) were not aware of all the surveys performed during the transfer process.
Subsequent investig tion by the Licensee indicated that the test results were not, for the most cart, easily retrievable, and hence, were unseen by the insp ec t c rs.
Ecwev :r, Radiological Field Operations did receive cinely i
telephone entificacica of sacole results and utlized the results in evaluating personnel protective requirements for the area.
An airborne tritium sacale log has been established to facilitate the trccking, recording, and retrieval of sample data.
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